As we noted in our blog post on August 8, we are concerned about restricting the use of OASIS field M1024 to fractures only. If implemented as written, we believe there is going to be a significant case mix (CM) decrease with unintended consequences for patients.
Our public comment offered the following solution:
Fully implement what “Attachment D” was meant for by collaborating with HHA industry expects and revising and updating Attachment D annually as both coding rules and HHA payment regulations are updated on an annual basis.
Do not restrict diagnoses codes limited to M1024 other than what is the intention of Attachment D. If it is the intent of CMS to control CM by limiting diagnosis to this field, a full cost analysis is needed prior to implementation.
- Mandate that only CM codes are placed in M1024 and not allow EMRs to allow otherwise. Have MACs audit for accuracy.
- Acknowledge the use of certified coders in homecare. Give them the ability to correct inaccurate coding by clinicians, with specific documentation on what was corrected and why.